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4.0 COMPLIANCE PLAN AND RECORD-KEEPING REQUIREMENTS • <br />40 CFR 61.01 specifies that the owner or operator of a stationary source subject to a NESHAP may be <br />required to obtain a Title V operating permit if the facility is a major source for HAPs. There is.not yet a <br />federal definition of "major" for radionuclide sources since radionuclide emissions are not measured in <br />terms of mass (EPA 1994, EPA 2000). The Sunday Mines are a minor source of both criteria pollutants <br />and HAPs in terms of mass-based emissions; therefore, a Title V operating permit will not be required for <br />these mines to demonstrate compliance with the Underground Uranium Mine NESHAP. This document <br />presents a compliance plan for demonstrating compliance with the Underground Uranium Mine <br />NESHAP. Denison will comply with all applicable requirements of 40 CFR 61, Subpart B. Denison will <br />also comply with any new requirement that becomes effective during the term of the Construction <br />Permits. <br />As prescribed by 40 CFR 61, Subpart B, Denison will conduct Rn-222 testing in accordance with the <br />procedures described in 40 CFR 61 Appendix B, Method 115, Section 1 ("Radon-222 Emissions from <br />Underground Uranium Mine Vents"). Specifically, Denison proposes to test Rn-222 emissions per <br />Sections 1.1.1 ("Continuous Measurement") and 1.2 ("Test Methods and Procedures"). Section 1.1.1 • <br />specifies that the Rn-222 concentration shall be continuously measured at each mine vent whenever the <br />mine ventilation system is operational. Weekly Rn-222 emission rates will be calculated and recorded for <br />each week utilizing monthly radon concentration data and quarterly ventilation rate measurements. <br />Denison will begin testing emissions from the vent holes within 90 days after initial mine startup, as <br />prescribed in 40 CFR 61.13. Method 115 also stipulates that each mine vent exhaust flow rate must be <br />measured at least four (4) times per year. Denison will comply with this requirement. <br />Method 115, Section 1.2 specifies test methods to be used to determine velocity traverses (40 CFR 60 <br />Appendix A, Method 1), and velocity and volumetric flow rates (40 CFR 60 Appendix A, Method 2). <br />Two options are presented for analysis of Rn-222 (Method A-6 or Method A-7 of 40 CFR 61 Appendix <br />B, Method 114). Denison proposes to use Method A-7 to analyze Rn-222. Denison will use <br />commercially-available, alpha track Rn-222 detectors to continuously collect Rn-222 emissions on a <br />monthly basis throughout the report year. Denison has used this methodology to fulfill similar EPA <br />requirements at other operational mines. Radon detectors will be placed in the mine vent air streams. At <br />the end of each month, a new radon detector will be placed in each mine vent air stream and spent radon <br />detectors will be sent to a qualified off-site laboratory to be read. <br />0 <br />4-1 <br />c:\doau u and settings`-d=ddocel selfingNa W-ly imd-d filablkC,s Y mires c.MJi.- Dl.Ldre4.d.